1 Wednesday, 24 May 2006

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4 [Open session]

5 THE REGISTRAR: Yes, Your Honour, we are in open session.

6 JUDGE MOLOTO: Thank you very much.

7 MR. WHITING: Thank you.

8 Q. Witness, I'd like to turn now to the year 1990. Did you become

9 aware in that year of a petition related to the insignia in the police?

10 A. Yeah. In 1990 I knew that there was a petition that was being

11 circulated around the police station and that was signed on that day when

12 I received that information by 12 police officers, i.e., by 12 authorised

13 personnel. The petition was relative to the fact that their uniform had

14 not been changed and the fact that the five-pointed star had not been

15 taken off.

16 THE INTERPRETER: The interpreter's correction.

17 THE WITNESS: [Interpretation] The fact that the -- that there were

18 intentions to change the uniform, but that those who signed the petition

19 did not want the uniforms to be changed or the five-pointed star to be

20 removed from the caps.

21 MR. WHITING:

22 Q. To your knowledge, did Milan Martic have anything to do with this

23 petition?

24 A. According to my information, Milan Martic did have to do with that

25 petition. He was one of the signatories of that petition.

1 Q. In August of 1990, were you aware of something called the log

2 revolution?

3 A. On the 17th of August, 1990, on the Serbian radio of Knin we could

4 hear alert signs and Dr. Milan Babic declaring the state of war.

5 Q. Just before that happened, did something happen at the police

6 station in Knin involving weapons? And if you could first just tell me

7 what you heard happened, and then we'll go into private session for you to

8 tell us how you heard that.

9 A. Yes. I heard that there had been a break-in into the -- into the

10 arms depot at the police station of Knin. I also heard that the arms had

11 been taken away from there.

12 Q. Did you hear anything about where they were taken?

13 A. I heard that the weapons had been taken to Golubic.

14 Q. Did you hear how many weapons approximately were taken?

15 A. There were long- and short-barrelled weapons as well as mines and

16 explosives in the police station, and their numbers corresponded to the

17 active and reserve police force numbers. In numbers, that would mean --

18 mean around 200 pieces altogether.

19 MR. WHITING: Your Honour, could we go into private session

20 briefly?

21 JUDGE MOLOTO: May the Chamber please move into private session.

22 [Private session]

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22 [Open session]

23 THE REGISTRAR: Your Honour, we are in open session.

24 JUDGE MOLOTO: Thank you very much.

25 Mr. Whiting.

1 MR. WHITING: Thank you, Your Honour.

2 Q. Witness, we're now in open session, so bear in mind what that

3 means.

4 In August of 1990, were barricades erected in the area around

5 Knin?

6 A. Yes, barricades were erected in the area of Knin. I personally

7 was able to see two such barricades, and I heard of the existence of three

8 more. When I was on my way to work commuting from Knin to Split, I saw

9 one such roadblock at the place called Konj in Vrbnik.

10 Q. And you said you saw a second barricade, and where was that?

11 A. The second one was in the place called Cenici -- or rather,

12 Ozegovici, which is opposite from Slavko Ozegovic's house, that's to say.

13 That's near the place called Klanac in the municipality of Drnis.

14 Q. Is that close to a place called Uzdolje?

15 A. This is one hamlet, as it were, in the village called Uzdolje.

16 The entire area is, in fact, the village of Uzdolje.

17 Q. These two barricades that you yourself saw, were they Serb

18 barricades or Croat barricades?

19 A. Those were Serb barricades.

20 Q. And what would happen when you went through those barricades?

21 A. As I was going through the barricades, vehicles were being

22 searched and checked.

23 Q. Did you observe any signs or markings at these barricades?

24 A. At Konj there were no signs indicating it was a barricade. There

25 were just two men standing along the road, and they were holding a sign,

1 usually -- normally used by the police, a stop sign, which they used to

2 pull the vehicles over.

3 Q. What about at the other barricade, did you observe any signs or

4 markings?

5 A. I did not observe any signs indicating who was manning the

6 barricades. The persons manning the barricades were variously dressed.

7 Someone had parts of military uniform, others parts of police uniform, and

8 others were in civilian clothes.

9 JUDGE NOSWORTHY: Sorry, at both locations or one or ...

10 THE WITNESS: [Interpretation] This was the case at both locations.

11 JUDGE NOSWORTHY: Thank you, Mr. Witness.

12 MR. WHITING: Thank you, Your Honour.

13 Q. Did the intermunicipal conference of the League of Communists of

14 Croatia for Dalmatia take a position with -- on these barricades?

15 A. Yes, the intermunicipal conference took a position on the

16 barricades, and this was at the gathering in August in 1990. It took a

17 position on the entire situation in Dalmatia, with specific reference to

18 Knin.

19 Q. And if you know, what was the position that it took?

20 A. The position of the intermunicipal conference of the League of

21 Communists of Croatia for Dalmatia was that all the members of the League

22 of Communists should do their best not to allow the situation to escalate,

23 that a single drop of blood is shed.

24 MR. WHITING: Could we go into private session briefly, Your

25 Honour?

1 JUDGE MOLOTO: May the Chamber please move into private session.

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24 [Open session]

25 THE REGISTRAR: Your Honour, we are in open session.

1 JUDGE MOLOTO: Thank you very much.

2 Yes, Mr. Whiting.

3 MR. WHITING: Thank you, Your Honour.

4 Q. Witness, we're now back in open session. From what you could

5 observe at the time, were these barricades, these Serb barricades,

6 defensive barricades?

7 A. Based on what I was able to observe, the barricades were not

8 defensive. First of all, based on my experience, I can tell you that the

9 barricade at Ozegovici, or as we call it Cenici, to be more precise that's

10 in the village of Uzdolje, had no other purpose than to psychologically

11 intimidate citizens of both ethnicities. Why do I say this? Firstly, on

12 the road from Knin to Sibenik, when one goes past the barricade at Cenici

13 or, that's to say, Ozegovici, there are villages with a Serb majority.

14 The town of Drnis itself had -- 20 per cent of the town residents were

15 Serbs.

16 Secondly, the barricade at Konj, since the entire place is called

17 Vrbnik and is in the immediate vicinity of Knin and borders with the

18 village of Potkonje where 55 per cent of the population were -- where --

19 THE INTERPRETER: Interpreter's correction.

20 THE WITNESS: [Interpretation] 95 per cent of the population were

21 Croats and 5 per cent were Serbs. On the basis of all this, I conclude

22 that the barricades had this psychological purpose of letting the village

23 of Potkonje know who the boss is in the area.

24 MR. WHITING:

25 Q. That -- that last example that you've given with respect to the

1 barricade at Konj and its effect that you saw that it had on the village

2 of Potkonje, that explains why you thought that the barricade had this

3 psychological purpose of intimidating Croat citizens. In your answer you

4 said that you thought it also had the purpose -- you said it had the

5 purpose of intimidating citizens of both ethnicities. Can you explain in

6 what way you thought it had the purpose of intimidating Serb civilians?

7 A. In what way could it have intimidated Serbs, too? You could never

8 know whether the person manning the barricade was sober or drunk, and

9 it -- and the person carried weapons. You never knew what his reaction

10 was going to be. The situation was no less horrific for the Serbs than it

11 was for Croats, although on the face of it it was directed at the citizens

12 of the other ethnicity.

13 Q. When you say it was directed at -- on the face of it it was

14 directed at citizens of the other ethnicity, do you mean on the face of it

15 it was directed against Croats?

16 A. That is my opinion.

17 I have to tell you something. In 1991 in the area of Knin,

18 88 per cent of the population were Serbs, 11 per cent were Croats, and

19 1 per cent were others.

20 MR. WHITING: Your Honour, I'm going to have to ask that we go

21 briefly into private session.

22 JUDGE MOLOTO: May the Chamber please move into private session.

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13 [Open session]

14 THE REGISTRAR: Your Honour, we are in open session.

15 JUDGE MOLOTO: Thank you very much.

16 Mr. Whiting.

17 MR. WHITING: Thank you, Your Honour.

18 Q. Witness, I want to change topics now and ask you about the media

19 at the time of the log revolution and after the log revolution, so in 1990

20 going into 1991. Can you tell the Trial Chamber what kind of media there

21 was in Knin and in the Krajina, and can you comment on what kinds of

22 things were being reported in these different medias?

23 A. Yes. In 1990, pursuant to a decision by the Municipal Assembly of

24 Knin and its council, the Serbian Radio Knin was set up and the Serbian

25 TV, later on to be called the television of the Republic of Serbian

1 Krajina. In 1990 and through to mid-1991, all the mass media,

2 particularly the press, arrived regularly in Knin; that's to say, the

3 media published in Belgrade, Zagreb, or Split.

4 Q. Can we focus first on the media that I'll call the Serb media,

5 that is the media that was from the -- from within the Krajina, either the

6 Serbian Radio of Knin or the Serbian television, or the media from

7 Belgrade. Can you tell the Trial Chamber how the -- this media reported

8 on the log revolution and on events that were occurring in the Krajina?

9 A. The media - and I'm predominantly referring here to the papers,

10 the press, but I will say something about the Serb TV later on - was

11 dominated by the Belgrade newspaper Express Politika, which took a

12 positive view of the log revolution and of the possibility for the

13 Republic of Serbian Krajina to become independent. In its reports, it

14 encouraged citizens to believe what the paper was reporting on.

15 Q. Witness -- witness, did this media talk about the Croatian

16 government or the Croatian people, and if it did, what did it say about

17 them?

18 A. The media reported on the Croatian government and the Croatian

19 people in the following way: That this was the government of the Ustasha,

20 that the Croats were Ustashas themselves, and that keeping in mind the

21 year 1940 and 1941, they ought not to be trusted and that a similar

22 scenario could be expected to take place at the time, too. They called on

23 the citizens of Serb ethnicity to respond to mobilisation call-ups in

24 order to defend Serb territories.

25 Q. And, Witness, when you said that the media said that a similar

1 scenario could be expected to take place at the time, what -- what

2 specifically were they talking about?

3 A. On the 30th of May, the HDZ came to power in Croatia, that is to

4 say the Croatian Democratic Union, which took a decision in the parliament

5 of Croatia to dissociate itself from the community of Yugoslav republics.

6 After that, the Serbs in Croatia no longer -- were no longer a constituent

7 nation. Therefore, after the 30th of May, the Serbs were no longer one of

8 the constituent peoples.

9 There was an incident in the parliament of Croatia when the son of

10 Janko Bobetko threw [realtime transcript read in error "through"] his

11 brief-case at [realtime transcript read in error "and"] Radislav Taniga,

12 who was one of the deputies of Serb ethnicity. And there was another

13 incident at Benkovac where Miroslav Mlinar was wounded.

14 Q. When you talked about the 30th of May, that was what year?

15 A. That was in 1991.

16 Q. Did the Serb media talk about or suggest that the Serbs in Croatia

17 in the Krajina were endangered by the Croatian government or by Croats?

18 A. Yes, that was rather common. It was reported that the Serb people

19 in Croatia were threatened by the newly appointed Croatian government.

20 JUDGE MOLOTO: Can I just get something on the record here clear.

21 On this page 38 at line 14, does the word "through" there mean through, or

22 threw, t-h-r-e-w? And his brief-case, is it now followed by at or and?

23 MR. WHITING: I can try to clarify that with the witness, Your

24 Honour.

25 JUDGE MOLOTO: Thank you.

1 MR. WHITING:

2 Q. Witness, you described an incident in the parliament of Croatia

3 involving the son of Janko Bobetko and Radislav Taniga. Could you just

4 repeat it -- what it is you said about that, what happened? What did

5 Janko Bobetko -- or rather, the son of Janko Bobetko do?

6 A. First let me say that Radislav Taniga was speaking and he was

7 speaking about the position of the Serb people in Croatia. Janko

8 Bobetko's son was very displeased with that speech and he threw his

9 brief-case at Radislav Taniga, who was speaking.

10 Q. Thank you, Witness. I think that clarifies it.

11 Now, you said that it was rather common and that it was reported

12 that the Serb people in Croatia were threatened by the newly appointed

13 Croatian government. Did you think, from what you could observe at the

14 time, that the Serb people in the Krajina were threatened by the Croatian

15 government or endangered?

16 A. In my view, based on my work, at that time there was no threat for

17 the Serb people by the Croatian government, and there were no signs that

18 what happened in 1941 would be repeated. I can confirm that by saying

19 that Jovan Raskovic, the president of the SDS, started negotiating with

20 the Croatian leadership, with the top leaders of the Croatian government.

21 Q. From what you could observe, did you think that the Croatian

22 government was seeking armed conflict with the Serb population?

23 A. One could not conclude that from the words or actions by either

24 the Croatian government or the Croatian president.

25 Q. Did you think at this time in 1990 and 1991 that armed conflict

1 was necessary to resolve the disputes between the Serbs and the Croats in

2 Croatia?

3 A. I think that the conflict could have been avoided, that there was

4 no need for the conflict. Dr. Milan Babic, the president of the Municipal

5 Assembly of Knin, started talking to a representative of the Ministry of

6 the Interior of the Republic of Croatia who hailed from Sinj. His name

7 was Jerko Vukas.

8 Q. Did the media, from what you could observe, have any effect on

9 Milan Martic's position in the Krajina?

10 A. The media did have an influence on the position of Milan Martic in

11 Krajina, all the media or nearly all the media from Serbia, save for the

12 Croatian media, spoke positively about Milan Martic and they hailed his

13 role in his request to protect the five-pointed star in his request to

14 protect the police and the Serb population in the area. He was welcomed

15 in his efforts.

16 Q. Did Milan Martic talk in the media about the Serbs in the Krajina

17 being endangered by the Croatian government or by the Croats?

18 A. Yes. Milan would often speak for the media. He would give

19 interviews, both for the Serbian media as well as for the Croatian media.

20 One of his last interviews that he gave to Nedina Dalmacija [phoen] which

21 is a paper of Slobodna Dalmacija from Split, and the journalist was Senel

22 Selimovic confirms from what I've just said so far.

23 Q. By the way, how did the -- you've made some references to the

24 Croatian media. How did the Croatian media compare to the Serbian media

25 in terms of what was being reported?

1 A. The Croatian media were much more tolerant. They encouraged

2 people to live together. They encouraged people to negotiate and to talk.

3 The only exception to that was the SD which is a paper that I had never

4 seen before that. The SD was rather extremist when it came to writing

5 about the Serb people in Croatia. The SD was published in Zagreb.

6 Q. I want to move on to another topic now. In 1991, did you learn

7 anything about a special-purpose unit of SAO Krajina MUP in Knin?

8 A. Yes, I was aware of that unit, which we referred to as the special

9 unit of SAO Krajina. It was billeted in the St. Ante's monastery in the

10 lower part of the town of Knin or the southern part of the town of Knin.

11 Q. Do you know who the commander of the unit was?

12 A. Dragan Karna was the commander of that unit.

13 Q. Without giving any names, did you know at that time any -- anybody

14 who was a member -- did you know personally anybody who was a member of

15 that unit or anybody's family who was a member of that unit?

16 A. I knew its members and their families.

17 Q. Did you have occasion to speak to those members and their families

18 about the unit and about what it did?

19 A. Yes. I spoke to them personally and to their families.

20 Q. Witness, could you tell the Trial Chamber, if you know, what the

21 duty or function of this special-purpose unit was, in particular whether

22 it had a duty or function in combat or fighting.

23 A. According to my information, that unit had a primary task to

24 protect the government of the Republic of Serbian Krajina, its president,

25 and Milan Martic personally. In other words, their primary task was

1 protection; its second task was to intervene in threatened areas. In

2 other words, it was prepared to intervene whenever the regular forces were

3 scarce, and that is the regular forces of the JNA first and then the Army

4 of Republic of Serbian Krajina.

5 Q. When it intervened in threatened areas, did it have a particular

6 function, to your knowledge?

7 A. I'm most familiar with the situation when the units -- when unit

8 was sent to break through the corridor. Other activities were either

9 individual or group activities. The unit never intervened as a whole.

10 Q. The reference that you made to the corridor, is that to the

11 Posavina corridor operation in 1992?

12 A. Yes, that was the Posavina corridor. Modrica, Derventa, and other

13 places belonging to that area.

14 Q. On other occasions when you said the -- the group operated either

15 individually -- as individuals or group activities, do you know what

16 their -- what duties they had with respect to fighting or combat? What

17 was their function or duty individually or as a group?

18 A. When they acted as individuals, the scenarios differed. They

19 would either blow up railways or they would enter in clashes with the

20 police force of the Ministry of the Interior of the Republic of Croatia.

21 Another duty was to intimidate people by blowing up kiosks or booths

22 belonging to the Croatian population of Knin.

23 Q. What was the purpose, if you know, of blowing up railways or

24 entering into clashes with the police force of the Ministry of the

25 Interior of the Republic of Croatia?

1 A. This was all covered by the media, and it was construed as the

2 Ustasha trying to attack the town of Knin.

3 Q. And in particular, what was the purpose of this -- of entering

4 into clashes with the police force of the Ministry of the Interior of the

5 Republic of Croatia, because I think your last answer may have just been

6 to the first part of the question. But what about the second part:

7 Entering into clashes with the police force. What was the purpose of

8 that, if you know?

9 A. The purpose was to show that this was an integral territory

10 governed by the Republic of Serbian Krajina and that no other could enter

11 the territory. Nobody who wasn't from the territory of the Republic of

12 Serbian Krajina, that is.

13 Q. You've told us before that you were present at Kijevo when it was

14 attacked in August of 1991. Did you encounter any SAO Krajina police

15 there, in Kijevo?

16 MR. MILOVANCEVIC: [Interpretation] Your Honour.

17 JUDGE MOLOTO: Yes, Mr. Milovancevic.

18 MR. MILOVANCEVIC: [Interpretation] My objection is that the

19 witness said that he wasn't in Kijevo, that he was somewhere else, either

20 at the observation point or a reconnaissance point, but that he wasn't in

21 Kijevo. And now the Prosecutor puts it to the witness: You said it, that

22 you were present at Kijevo.

23 JUDGE MOLOTO: Mr. Whiting.

24 MR. WHITING: Your Honour, my recollection is otherwise, but

25 I'll -- if I could just have a moment.

1 JUDGE MOLOTO: This is yesterday's testimony?

2 MR. WHITING: That's correct, Your Honour.

3 JUDGE MOLOTO: I also have a recollection about that, but I will

4 reserve it.

5 MR. WHITING: The transcript will tell us.

6 Your Honour, if we could just go into private session because it

7 starts to get kind of specific.

8 JUDGE MOLOTO: May the Chamber please move into private session.

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12 THE REGISTRAR: Your Honour, we are in open session.

13 JUDGE MOLOTO: Thank you very much.

14 Mr. Whiting.

15 MR. WHITING: Thank you, Your Honour.

16 Q. Witness, now -- please just don't specify which unit you were a

17 part of or why -- what brought you to Kijevo, but I'm not sure you

18 answered my last question which was when -- and if you don't -- if you

19 don't know, just say you don't know. But if you -- when units were sent

20 to mop up an area, were -- what were they to do about civilians in the

21 area, if anything?

22 A. I understood your question, but I did not complete my answer. I

23 would say that our task was - that is, the task of the company that I was

24 with - to protect the civilian population. And, if at all possible, we

25 were to offer them to leave the scene; and if not, we were to ask them to

1 stay in their houses, not leave their houses until the complete war

2 operation was over and until the moment the mop-up was completed as well.

3 Q. Now, I'll go back to my earlier question. When you were in

4 Kijevo - and now we've established that that was actually on the 27th of

5 August of 1991 - did you encounter SAO Krajina police there?

6 A. As we were descending from the Radici huts and as we reached the

7 Knin-Split road, we also came across the road leading from Kijevo to

8 Unista, which is a place in Bosnia and Herzegovina. I met several persons

9 or, rather, police officers of the SAO Krajina. They asked me -- can I

10 complete my answer?

11 Q. Yes, please, if you would.

12 A. One of the persons asked me why -- what we were waiting for, why

13 didn't we start torching the place. And I told him that we never intended

14 to do that. After that, I could see that there was a house in the centre

15 of Kijevo and a couple of houses on the other end of Kijevo that started

16 burning.

17 MR. WHITING: If I could just ask one or two more questions, Your

18 Honour, just to finish this topic. I know, I'm sorry, but just -- we'll

19 finish this topic.

20 Q. You said that this person said: Why didn't -- why don't we start

21 torching the place? And you gestured actually with your hand in a

22 pointing gesture. Just so the record is clear, what place was he

23 referring to?

24 A. The place called Jurici, in the direction of Bajani, in the area

25 of Kijevo.

1 Q. Is that part of Kijevo or is that next to Kijevo?

2 A. Yes, it's a part of Kijevo.

3 Q. And just a last question on this topic. You said that after that

4 you saw a house in the centre of Kijevo and a couple of houses on the

5 other end of Kijevo that started burning. Were you able to tell whether

6 those houses were set on fire on purpose or as a result of the combat, if

7 you could tell?

8 A. There were no combat activities in Kijevo on the 27th. Therefore,

9 I presume the houses were set on fire deliberately.

10 Q. Thank you, Witness.

11 MR. WHITING: Your Honour, I apologise for going over, and I think

12 now it's a convenient time.

13 JUDGE MOLOTO: Not a problem.

14 We'll take a short break, come back at half past 12.00.

15 Court adjourned.

16 --- Recess taken at 12.03 p.m.

17 --- On resuming at 12.31 p.m.

18 JUDGE MOLOTO: Yes, Mr. Whiting.

19 MR. WHITING: Thank you, Your Honour.

20 Q. Witness, we're in public session. I want to ask you some more

21 questions about the special-purpose unit from Knin. Do you know where

22 they did their training?

23 A. Not all of them but most of them were trained at Golubic, which

24 was formerly a place where youth passed their vacation, and Gruska, near

25 Benkovac.

1 Q. Do you know who did the training at Golubic?

2 A. I don't know all of them, but I know that Captain Dragan was

3 present also at Golubic, whereas he ran the camp at Gruska.

4 Q. Is that Gruska or Bruska?

5 A. B, as in Berlin.

6 Q. Thank you, Witness. Do you know what Milan Martic's relationship

7 was to the training camp at Golubic?

8 A. Milan Martic set up the centre at Golubic.

9 MR. WHITING: Could we go into private session, please, Your

10 Honour.

11 JUDGE MOLOTO: May the Chamber please move into private session.

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22 [Open session]

23 THE REGISTRAR: Your Honour, we are in private session.

24 JUDGE MOLOTO: Thank you very much.

25 Yes, Mr. Whiting.

1 MR. WHITING: Thank you, Your Honour.

2 Q. Witness, you've made a reference to the term "Marticevci." Could

3 you tell us what that term referred to. And now I'm speaking about 1991.

4 A. Yes. Marticevci referred to all the people who successfully

5 completed the training at Golubic. In the eye of the citizens, they were

6 a higher level of specialists, an elite, as it were, compared to the other

7 staff that we had in the police ranks.

8 Q. Were the other staff that you had in the police ranks ever

9 referred to as Marticevci, or was it only, to your knowledge, those who

10 were trained at Golubic?

11 A. Upon completing the training at Golubic, all those who were

12 employed in the police station were called Martic's men, Marticevci. This

13 might not have been the case right at the start, in 1991 and 1992, but

14 later on all of them were referred to as Marticevci.

15 Q. But just to be clear, in 1991 did -- do you know if that included

16 the regular police?

17 A. No, not the regular police.

18 Q. And why were the -- the police that were trained at Golubic

19 referred to as Marticevci? Why did they have that name?

20 A. It was thought that these men were more capable, trained, and even

21 more loyal to the system.

22 Q. But specifically why that name, "Marticevci"? What was the reason

23 for that name?

24 A. Well, if Martic set up the whole thing and was the secretary, this

25 is self-explanatory. It shows that it was after him that it -- they were

1 named.

2 Q. Now, from what you could observe and from your various sources of

3 information, could you tell us what the reputation of the Marticevci was

4 in 1991?

5 A. At the start of training, when the camp was opened, the people

6 reacted positively and with delight because they thought that this was

7 going to produce capable, young personnel that were going to be able to

8 deal with the war. As the time went by and as the war developed, they

9 were gaining their popularity, and so it went until the end of the war.

10 Q. So did they have a good reputation?

11 A. Well, they had a good reputation at the start, but in the end

12 their reputation was bad.

13 Q. And when you say it was bad, can you be more specific. Why was it

14 bad?

15 A. I can, because I suppose I shall be mentioning some names and

16 events later on because some of them did not behave honourably toward

17 their fellow citizens, their property, and toward their people.

18 Q. I will be asking you some more specific questions later, but I

19 will come back to this to make sure that I have addressed all the examples

20 that you're thinking of now. But for now I'm going to move on to another

21 topic.

22 Was there -- to your knowledge, in 1991 was there a prison in

23 Knin?

24 A. Yes, there was a prison in Knin. I know of it. I heard of it.

25 Q. To your knowledge, where was it located?

1 A. The civilian prison, we're talking about the civilian prison -- I

2 don't know about the military. The civilian prison was located in the old

3 Knin hospital.

4 Q. I want to ask you about the Territorial Defence. In 1991, do you

5 know who was in command of the Territorial Defence in Knin?

6 A. In 1991, the commander of the staff of the Territorial Defence was

7 Mr. Milan Dragisic.

8 Q. Do you know what his relationship was to Milan Martic?

9 A. As far as I know, their relationship was a correct one --

10 THE INTERPRETER: Could the witness please repeat the last part of

11 his answer.

12 MR. WHITING:

13 Q. Witness, the interpreter couldn't hear the last part of your

14 answer. Could you just repeat that answer?

15 A. Milan Dragisic married Milan's sister.

16 Q. And when you say he -- Milan Dragisic married Milan's sister,

17 you're speaking about Milan Martic's sister?

18 A. Yes, Milan Martic's sister, Neda.

19 Q. I want to go back now to the attack on Kijevo on --

20 JUDGE MOLOTO: Can I just -- before you go to that point.

21 Following up the question on relationship between Milan Dragisic

22 and Milan Martic, in terms of their work position, was there any

23 relationship?

24 THE WITNESS: [Interpretation] There had to have been one, as was

25 the case in the former system. The commander of the TO staff, the

1 secretary for the police and the secretary of the Secretariat for National

2 Defence had to have daily or frequent contacts in order to be fully

3 informed of the situation on the ground.

4 JUDGE MOLOTO: Now, was that the legal relationship, that the one

5 was the commander of the TO staff and the other was the secretary of the

6 Secretariat of the National Defence, and that they were in the same --

7 were these people -- were these posts -- are these posts in the same

8 department, if I may ask that way?

9 THE WITNESS: This wasn't the same department, but the area of

10 their activity was similar. The Territorial Defence dealt with the

11 territory and the people defending the territory, whereas the national

12 defence was in charge of carrying out mobilisation and selecting

13 personnel.

14 JUDGE MOLOTO: Thank you very much.

15 Mr. Whiting.

16 MR. WHITING:

17 Q. And just to follow up on that question. In your first answer you

18 said -- you included the command of TO staff, the secretary of the

19 police, and the secretary of the Secretariat for National Defence. Did

20 these -- from what you could observe during 1991, did these entities work

21 together along with the JNA during the conflict in the Krajina, before the

22 conflict began and when the conflict began?

23 A. All the three institutions were separate, but they formed a whole

24 in terms of security. And by virtue of their function, they had to have

25 daily contacts with the command of the Yugoslav People's Army.

1 Q. Thank you. Now I want to move back to ask some more questions

2 about the attack on Kijevo on the 26th of August, 1991.

3 From what you could observe and learn from your role, which we've

4 talked about in private session and we won't repeat now in public session,

5 were you able to determine what the objective of that attack was on

6 Kijevo?

7 A. In my view, the objective of that attack was to liberate the area

8 and to provide for the further advances and activities of the JNA. Since

9 Kijevo is between Polaca and Civljani and it was inhabited by Croats only,

10 there are 100 per cent Croats living in that village, and between Civljani

11 and Polaca which were inhabited by the Serbs, this area should be opened

12 to provide for an unhindered advance towards Velika and Sinj.

13 Q. To your knowledge, did the Croats who were living in Kijevo pose a

14 threat to the Serbs?

15 A. No. I stress once again, the Croat citizens in the territory of

16 Knin, that Kijevo was also part of, could not present or pose any threat

17 to either the Serb population or the town of Knin. And I underline once

18 again, in 1991 88 per cent of the population were Serbs, 11 per cent of

19 the population were Croats.

20 Q. Do you know if there were any Croatian forces, military or police,

21 located in Kijevo that posed a threat to the Serbs in August of 1991?

22 A. I knew and I saw the forces of the Ministry of the Interior of the

23 Republic of Croatia billeted in the culture hall in Kijevo. They

24 controlled the area, the area covering the whole territory of Kijevo, and

25 practically they never left the premises that they were billeted at.

1 Q. From what you learned and could observe, did those forces of the

2 Ministry of the Interior of the Republic of Croatia who were billeted in

3 the culture hall in Kijevo, did they pose any threat to Serb -- Serbs or

4 Serb forces in the area?

5 A. Again, I was involved in certain duties in my unit, and we did not

6 perceive them as posing threat to the general population in the territory

7 of Knin.

8 Q. Witness, during the attack on Kijevo, was the church in Kijevo

9 damaged?

10 A. Unfortunately, it was. The church was damaged. This was the

11 St. Michael's church which was located on a hill from where there was a

12 good view and it could be seen from afar. The church was damaged on

13 the 26th of August, on the day of the conflict, and the intention was to

14 show -- because prior to that most of the population had left and the

15 intention was to show those who were -- who stayed there that there was

16 nothing for them to look forward to. Your village has been torched, your

17 church has been damaged, so it's best for you to leave that place.

18 Q. Witness, during that attack on Kijevo, was the village of Vrljika

19 also attacked?

20 A. Yes. The forces of the JNA set off towards Vrljika.

21 Q. And what happened at Vrljika?

22 A. Vrljika was taken by the JNA in less time than it took them to

23 take Kijevo.

24 Q. What happened after the JNA took Vrljika?

25 A. Once Vrljika was taken, they moved on in the direction of Sinj.

1 Q. And what happened after that in Vrljika?

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6 Q. Was somebody appointed to be chief of police in Vrljika?

7 A. The police station in Vrljika was set up once Vrljika was taken

8 and it was Djuro Togajic who was appointed its commander; he was an active

9 police officer from Knin. And the police station of Vrljika reported

10 directly to the police station in Knin.

11 Q. To your knowledge, was Djuro Togajic a subordinate to Milan Martic

12 when he became chief of police of Vrljika?

13 A. Yes, he was subordinated to him.

14 Q. And did any looting occur in Vrljika?

15 A. Yes. Unfortunately, the command of the JNA issued a ban on

16 looting and placed the military police at all points to control the

17 troops. However, this did not apply to the civilian police. There was

18 looting, therefor, and almost everybody took part in the looting, save for

19 the troops of the JNA.

20 Q. Did the police take part in the looting?

21 A. I did not see anybody directly, but indirectly I would say yes.

22 When I say "indirectly," I would say that whenever they controlled traffic

23 they let go all the lorries that carried goods looted from the area and

24 they went on and they proceeded towards Knin with that -- those looted

25 goods.

1 Q. Did you see that?

2 A. I did. The company that I belonged to was billeted in

3 Kosorska Greda.

4 Q. And when that looting occurred in the areas that were controlled

5 by the police or where the police controlled the traffic, was that after

6 Djuro Togajic had been appointed to be the chief of police of Vrljika?

7 A. Yes, after that.

8 Q. Witness, I want to ask you about a different topic now, about

9 Drnis. Was there an attack on Drnis in September of 1991?

10 A. Yes. The attack on Drnis was in the afternoon hours of the 16th

11 of September, 1991.

12 Q. And just for the benefit of the Trial Chamber, Vrljika is located

13 on the atlas, Exhibit 23, on page 31, in grid C2, just south of Kijevo and

14 Civljani, and Drnis is also located within that same grid. It can be

15 found near -- just directly south of Knin to the left of the crease. So

16 it's actually on page 30, but in that same grid, C2.

17 MR. WHITING: Could we go into private session briefly, Your

18 Honour?

19 JUDGE MOLOTO: May the Chamber please go into private session.

20 And maybe before -- yeah.

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6 THE REGISTRAR: We are in open session.

7 JUDGE MOLOTO: Thank you very much.

8 Yes, Mr. Whiting.

9 MR. WHITING: Thank you, Your Honour.

10 Q. Witness, when you were in Drnis on the 17th of September and

11 thereafter, what did you observe happen there?

12 A. First of all, I found the centre of town to be completely

13 destroyed; secondly, some of the Croatian citizens who stayed behind were

14 very concerned; and thirdly, I came across incredible large-scale looting.

15 Q. Who was engaged in the looting, as far as you could see?

16 A. As far as I was able to see, everyone did. The army, the police,

17 and citizens. The army was particularly focussed on a winery there where

18 a large amount of barrels of wine was left behind.

19 Q. Witness, you said that the -- some of the Croatian citizens who

20 stayed behind were very concerned. Why were they very concerned?

21 A. First of all, after the shelling of the town, the bombing, and

22 after the torching of the centre of town, which is -- which was a small

23 town, really, they were concerned about their future, what was to come the

24 following day. Secondly, they were wondering what to do about the

25 looting. They were powerless in the face of looters. They feared for

1 their lives. They felt insecure.

2 Q. What was -- what was -- do you know what the population of Drnis

3 was in terms of ethnicity?

4 A. 75 per cent were Croats; 25 per cent were Serbs.

5 Q. What was the effect of the attack on Drnis in terms of the town or

6 village itself? What happened to the village physically? You said that

7 the centre of town was destroyed. Did that -- did it affect other parts

8 of the town?

9 A. Yes, it affected other parts of the town as well. What was the

10 purpose of this exercise in Drnis? Well, I have to tell you that the

11 Drnis-Sibenik road passes by two villages where the majority population

12 was Serbs. One of them is Zitnic, where the ratio was 65 to 35, the

13 majority being Serbs; and the village of Konjovrate [phoen], where the

14 ratio was 70 to 30; 70 per cent were Serbs, 30 per cent were Croats. The

15 strategy was probably that of protecting these villages which were on the

16 front line. There is a second version, though, according to which the

17 Yugoslav People's Army set off toward Sibenik with the intention of

18 joining up, linking up, with the other units which were headed toward

19 Sibenik from the area of Benkovac, that's to say from the western side.

20 Q. Witness, to your knowledge in September of 1991, did -- did Drnis

21 pose any threat to Serbs or to Serb forces?

22 A. I have the same opinion as I had then, and I will probably have

23 the same opinion throughout my life. Drnis did not pose any danger to the

24 Serb residents of the town of Knin at the time.

25 Q. Do you know who the police commander was at that time in Drnis?

1 A. I know that they changed quite often. I know of two of them who

2 held the position. One was at the start. His name was Obrad Bujanic,

3 also known as Sveto, who held the position for a very brief period of

4 time. The other one was Drago Rajic. In view of the fact that I left the

5 area, I was unable to follow the situation to know who held the position.

6 Q. Do you know who had the position in the days after the attack on

7 Drnis on September 16th, 1991?

8 A. I don't understand. Could you please clarify your question.

9 Q. I'm sorry, and -- was -- do you know if -- in the -- on the 16th

10 of September, the 17th of September, the 18th of September, was it Obrad

11 Bujanic who was the chief of police, Drago Rajic, or somebody else?

12 A. At the time, there was no police station at Drnis. It was only

13 some 10 to 15 days later that it was set up.

14 Q. And when it was set up 10 to 15 days later, was it -- was that

15 when it was first Obrad Bujanic for a short time and then Drago Rajic?

16 A. Yes, as far as I remember.

17 Q. Were they, to your knowledge, subordinated to Milan Martic?

18 A. Yes. They, too, were subordinated to Milan Martic.

19 Q. Did something happen in Potkonje in 1991?

20 A. Yes. The municipal secretariat of the interior of Knin carried

21 out an incursion into the village of Potkonje.

22 Q. When was that?

23 A. That was in 1991. At any rate, it was before the month of June,

24 sometime during that period.

25 Q. Can you tell us where Potkonje is located in relation to Knin?

1 A. In relation to Knin, Potkonje is to the south.

2 Q. How far to the south?

3 A. About two and a half kilometres.

4 MR. WHITING: Your Honours, I don't think this appears on the

5 atlas.

6 Q. You told us that the municipal secretariat of the interior of Knin

7 carried out an incursion into the village of Potkonje. Can you tell us

8 specifically what happened, to your knowledge?

9 A. To my knowledge, based on the stories I heard from people, in view

10 of the fact that there were several mixed marriages - I don't like using

11 that term, but it's more understandable that way - it happened that the

12 municipal secretariat of the interior was informed of the village of

13 Potkonje having been arming itself. That was when an action was carried

14 out, an action searching for weapons. There was stories about a radio

15 station being active in Potkonje where Croat citizens or Croat villagers

16 were informing someone about the events at Knin.

17 Q. And so what did the police do in Potkonje?

18 A. The police searched the area. The search was probably accompanied

19 by some other things. I cannot really tell you what, but from

20 conversations with some people -- I don't know if at this stage ...

21 Q. Just leave it at that and we'll go into private session, and I'll

22 ask you who specifically with -- which people, but if you could just

23 continue -- what you heard about what happened in Potkonje.

24 A. We heard from one participant, a police officer, who told me at

25 the end of the town that they had wreaked havoc down there. And I asked:

1 Down where? And he told me: We were down at Potkonje. We searched the

2 area. He didn't tell me whether they found any weapons, and he didn't

3 tell me whether they found a radio set.

4 Q. Did -- from what you were able to learn, did this event in

5 Potkonje have any effect on civilians, Croat civilians, living in that

6 village?

7 A. To my knowledge, nobody was killed. Whether someone was beaten

8 up, I cannot say, I don't know, but the psychological effects were

9 devastating.

10 Q. Can you explain that. Why do you say that? What do you mean when

11 you say "the psychological effects were devastating"?

12 A. First of all, this was a rather small village; secondly, I said

13 that there were several mixed marriages there where Croats and Serbs

14 married each other; thirdly, the village was adjacent to the village of

15 Vrbnik, which was inhabited 100 per cent by Serbs. If the official

16 authorities searched the village for weapons, the question was now: What

17 would -- what would everyone else do now if they thought that we had

18 weapons? What would happen to us next.

19 Q. So did the Croat civilians who were living in Potkonje do anything

20 after this event? Did they stay in Potkonje or did they leave?

21 A. No, they didn't stay there; they left.

22 Q. And from what you could observe and from what you heard, was that

23 one of the purposes of the incursion into Potkonje or was that just an

24 unintended effect?

25 A. Probably the party organising this excursion into Potkonje gave

1 careful thought to what sort of effect that would have.

2 MR. WHITING: Could we go into private session, please?

3 JUDGE MOLOTO: May the Chamber please move into private session.

4 [Private session]

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23 [Open session]

24 THE REGISTRAR: Your Honour, we are now in open session.

25 JUDGE MOLOTO: Thank you very much.

1 Mr. Whiting.

2 MR. WHITING: Thank you, Your Honour.

3 Q. Witness, how were the events in Potkonje talked about in the

4 media?

5 A. The Serbian radio of Knin said that some of the citizens were

6 arming themselves and that this was learned by the municipal secretariat,

7 that a search had been carried out, that there were no injured or wounded,

8 and that the search had been staged in order to provide for the safety of

9 the citizens of Knin.

10 The newspapers in Croatia, however, carried negative reports on

11 the event. At the same time, the Yugoslav papers said that this was a

12 good thing and that any illegal armament should be prevented. And that's

13 why this whole thing was good.

14 Q. I'd like to move to another topic now. Did you hear of something

15 that happened in Skabrnja and Nadin in November of 1991?

16 A. I didn't hear anything of Nadin or about Nadin. I did not have

17 any information about that. Nadin was not commented publicly in the town

18 of Knin.

19 As for Skabrnja, for a few days I didn't know what had happened

20 there. It was only then when all sorts of information started leaking to

21 the effect that there had been a massacre of civilians. It was not

22 publicly known. However, a mother who had lost her son asked me if I was

23 aware of his destiny, whether he was among those people. I said I didn't

24 know because my position was to the opposite side of where this event had

25 taken place. The only thing I know is what I learned from the media and

1 from the mother who came to me.

2 And I know something else, also. A man whose family name was

3 Crnogorac and whose first name I didn't know came to my unit and told me

4 that he had participated in the attack on Skabrnja, but he could not hold

5 the pressure. And he also told me that Captain Dragan was paying them 20

6 German marks for a day of fighting. According to him, he was there, but

7 he had not participated in the massacre and he did not have any say in

8 that massacre. And this is the long and the short of what I know of this

9 massacre in Skabrnja.

10 Q. Just to be clear, you said that -- you said in your answer: As

11 for Skabrnja, for a few days I didn't know what had happened there. It

12 was only then when all sorts of information started leaking to the effect

13 that there had been a massacre of civilians. So just to be clear, did you

14 hear those stories of a massacre of civilians a few days after the attack

15 on Skabrnja?

16 A. Yes, a few days after the attack on Skabrnja we heard about this

17 massacre of civilians. For a few days, the first day, the second day, and

18 the third day following the attack, I didn't know what had happened there.

19 Q. You also stated that you heard that Captain Dragan was paying

20 people 20 German marks for a day of fighting at Skabrnja. On this

21 subject, did you make a correction to your ICTY statement on this topic?

22 Did you say something different in your ICTY statement that you've now

23 corrected?

24 A. It is possible that in my statement I stated that the person

25 involved was Arkan; however, I never saw Arkan there at the time. But I

1 did hear from other people that Captain Dragan was there, and I also heard

2 from that guy who had returned from the scene that it was Dragan --

3 Captain Dragan who was involved. So it wasn't Arkan but Captain Dragan,

4 if that is what you had in mind when you put your question to me.

5 Q. That was precisely what I had in mind. Thank you.

6 Could you tell us how the media -- how the Serb media talked about

7 the attack on Skabrnja?

8 A. The reactions were not hysterical, so to speak, and there was a

9 bit of justifying the whole thing by saying that this was a military

10 operation, that the targets could not be selected. There was not much

11 celebration is what I meant when I said the reaction was not hysterical,

12 but still justifications were being sought for what had happened.

13 MR. WHITING: Your Honour, could we go into private session

14 briefly, please?

15 JUDGE MOLOTO: May the Chamber please move into private session.

16 [Private session]

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11 THE REGISTRAR: Your Honour, we are now in open session.

12 JUDGE MOLOTO: Thank you very much.

13 Yes, Mr. Whiting.

14 MR. WHITING: Thank you, Your Honour.

15 Q. Witness, I want to move to something that occurred in 1992. In

16 that year, did something happen at the Dom Kulture or cultural centre in

17 Knin?

18 A. It was in 1992 but not in Knin but in Vrpolje, which is a place

19 close to Knin, if you're talking about Dom Kulture, if that is what you're

20 referring to.

21 Q. Yes, that was my mistake, I apologise. Thank you for catching

22 that.

23 Can you describe for us -- you say that Vrpolje is a place close

24 to Knin. Can you describe to us where it is in relation to Knin and how

25 far away?

1 A. Vrpolje is five kilometres north of Knin.

2 Q. And what happened at the Dom Kulture or cultural centre in Vrpolje

3 in 1992?

4 A. Dom Kulture in Vrpolje was -- again, I'm not using these terms in

5 my everyday vocabulary, I'm just using them for a better understanding.

6 This was a collection centre for the citizens of Knin of Croatian

7 ethnicity. In 1992, it became a point where Croatian citizens who, under

8 various circumstances, wanted to leave the town of Knin and the Republic

9 of Serbian Krajina to join their families. This is where they were

10 accommodated. And it was so until the year 1993 when the last Croatian

11 citizens left Knin, i.e., after Operation Maslenica, the last citizens of

12 Croat ethnicity left Knin.

13 Q. Now, Witness, when you say that these Croatian citizens would go

14 to this location when they were leaving Knin, when they wanted to leave

15 the town of Knin in the Republic of the Serbian Krajina, from what you

16 could observe, were they leaving because they wanted to go or because they

17 were pressured to leave?

18 A. First of all, I have to tell you that there was a constant

19 pressure on the Croatian citizens of Knin; this started in the year 1990

20 when their businesses were being blown up, when there was not a single

21 night in Knin without an explosion. Some of these explosions did not have

22 any consequences, and as a result of some of the others that things were

23 destroyed. And one couldn't live like that.

24 There was another danger for the Croat citizens, and that happened

25 whenever a Serb soldier got killed, there was always a danger of

1 retaliation. In other words, there was a very high degree of insecurity.

2 My last Croat citizen who left Knin, and I can tell you his name and

3 family name, but maybe not now, maybe we should do it later. He cried

4 before my wife's eyes, asking her to ask me to help him. I wasn't home at

5 the time. Also I know that he asked an employee of Mr. Martic to allow

6 him to stay rather than become a refugee. I offered this man to share my

7 apartment, the apartment that was -- that had 60 square metres. I did not

8 manage to persuade him to stay and eventually he left Knin.

9 Q. Do you know what Mr. Martic said when he -- when this man asked

10 Mr. Martic to be able to stay rather than become a refugee?

11 A. I don't know what he told him, but I know that he was as sad as I

12 was.

13 MR. WHITING: I think that would be a convenient time, Your

14 Honour.

15 JUDGE MOLOTO: Court will adjourn. We reconvene tomorrow morning

16 at 9.00.

17 Court adjourned.

18 --- Whereupon the hearing adjourned at 1.46 p.m.,

19 to be reconvened on Thursday, the 25th day of

20 May, 2006, at 9.00 a.m.

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